Facts:

The case involves Bonifacio Balmes as the plaintiff-appellee and Fortunato Suson as the defendant-appellant. The dispute concerns a sixteen-hectare parcel of public land, designated as Lot 2104, Pls-61, located in Molave, Zamboanga del Sur. The conflict traces back to administrative proceedings that began in 1941, wherein the Director of Lands decided in favor of Balmes regarding the land in question after he filed Sales Application 22992. Despite this ruling, Suson and his son Aproniano sought reconsideration, which was denied repeatedly up until 1956. The Director of Lands had ordered Suson to vacate the premises and warned of forfeiture of his improvements if he failed to comply. Balmes, who had been deprived of possession since 1939 following a forcible dispossession by Suson, sought judicial relief to recover possession and damages. After facing delays from Suson, including a petition for executive review with the Office of the President, which was ultimately dismissed in 1

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Facts:

Background and Administrative Proceedings

• The dispute centers on a sixteen-hectare public land known as Lot 2104, Pls-61, located in Molave, Zamboanga del Sur.
• The case originated from a pre-war decision involving a preferential right to possession of the land, with the dispute dating back to 1939 when the plaintiff, Bonifacio Balmes, was deprived of possession by the defendant, Fortunato Suson.
• On August 16, 1941, the Director of Lands rendered a decision (Lands Conflict 374) in favor of Balmes (Sales Application 22992) and against Suson.
• A reconsideration by Aproniano Suson, Fortunato’s son, filed on or around the same period (August 23, 1941) was rejected.

Subsequent Administrative Actions and Reinforcement

• On December 6, 1948, Fortunato Suson initiated a reconsideration on his own behalf, objecting that his son’s earlier motion was filed without his consent.
• The Lands Bureau reinvestigated the case, resulting in a detailed decision by the Director of Lands on October 8, 1954, which:
• Rejected Suson’s claim to Lot 2104 (B.L. Claim 188(N));
• Ruled that Balmes’ sales application “shall be given due course”;
• Directed that Suson vacate the lot and remove all improvements within 60 days or face forfeiture of those improvements in favor of the Government.
• On August 13, 1955, the Secretary of Agriculture and Natural Resources affirmed the Director’s decision.
• Three subsequent motions for reconsideration by Suson were filed—on January 5, 1956, April 26, 1956, and July 16, 1956—and were all dismissed on the ground that they were time-barred.
• The Secretary’s ruling emphasized that Suson’s improvements were introduced in bad faith, noting that he continued to occupy the lot despite the adverse decision since 1941.

Transition to Judicial Relief

• Following the administrative decisions, Bonifacio Balmes sought execution of the Director’s decision on October 20, 1956, December 5, 1956, and February 2, 1957.
• The Undersecretary of Agriculture and Natural Resources later directed the Lands Director to implement the decision after a ten-day reporting order on March 11, 1957.
• Plaintiff ultimately filed a case in the Court of First Instance of Zamboanga del Sur for possession of the land and damages, claiming that the administrative decision was long final and executory.
• In response, defendant Suson filed a petition for executive review with the Office of the President on July 3, 1957, and simultaneously moved to dismiss the court action on the grounds of prematurity and lack of jurisdiction due to the pending petition.

Judicial Proceedings and Relief Sought

• On July 20, 1957, the trial court rejected Suson’s motion to dismiss.
• Defendant subsequently filed a petition for certiorari and prohibition with the Supreme Court (docketed as G.R. L-12868) contending:
• The trial court lacked jurisdiction given that an executive review was pending;
• All administrative remedies had not been exhausted.
• The Supreme Court, on October 8, 1957, dismissed the petition for lack of merit and later denied a motion for reconsideration on October 15, 1957.
• Final judgment in the lower court (rendering orders for possession, damages, attorneys’ fees, and costs) was rendered after the parties entered a stipulation of facts on October 8, 1958, with evidence presented solely on the issue of damages.

Resolution on the Executive Review and Additional Relief

• The petitioner’s main administrative appeal was ultimately resolved by the Office of the President on February 12, 1964, dismissing the appeal.
• The Presidential decision recognized Balmes’ undisputed possession from 1934 until his forcible dispossession in 1939 and affirmed that Balmes had the better right to the lot.
• The lower court also awarded damages of ₱3,000 for litigation expenses and ₱500 for attorneys’ fees, both of which were later reviewed by the Supreme Court, which modified the attorneys’ fees award to ₱1,500.

Issue:

Jurisdictional Issue

• Whether the lower court acquired jurisdiction to entertain the case despite the pendency of Suson’s petition for executive review pending with the Office of the President.
• Whether the filing of an administrative appeal to the President, as the highest administrative authority on matters of public land, constitutes the exhaustion of all administrative remedies, precluding immediate resort to the courts.

Award for Damages and Attorneys’ Fees

• The propriety of awarding damages amounting to ₱3,000 to compensate for the expenses incurred by the plaintiff in enforcing the administrative decision, when such expenses were neither clearly alleged in the complaint nor the subject of contention initially.
• The correctness of awarding ₱500 for attorneys’ fees, with subsequent evaluation of whether such fees were adequate considering the evidence presented and the scope of legal services rendered.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)